White & Case LLP - Lawyers - Linda E. Carlisle

Practice Experience

Linda E. Carlisle practices international and domestic tax law and concentrates within the areas of taxation of corporations and corporate reorganizations, flow through entities, such as partnerships, limited liability companies, as well as Subchapter S corporations. She also focuses on Public-Private Partnerships (or PPPs) and infrastructure transactions, and is one of the foremost practitioners in this area. In addition, Ms. Carlisle assists clients with employee stock ownership plans (“ESOPs”), intercompany pricing issues, financial derivative product issues and legislative, regulatory and administrative tax matters.

Ms. Carlisle advises on acquisitions and divestments of US companies and businesses and in the establishment of finance structures and holding companies. She assists clients in structuring hybrid financial instruments and in devising and defending transfer pricing.

She also has testified before the US Congress, obtained advance tax rulings approving proposed transactions, achieved favorable administrative and judicial resolutions of tax adjustments proposed by the US Internal Revenue Service, obtained refunds of overpaid US tax and has successfully contested proposed foreign tax adjustments through tax treaty provisions ("competent authority" proceedings).

Prior to joining White & Case LLP, Ms. Carlisle was in government service with the US Department of the Treasury as an Attorney-Advisor in the Office of the Tax Legislative Counsel and as the Special Assistant to the Assistant Secretary for Tax Policy. Ms. Carlisle is a frequent speaker on domestic and international tax issues.

Bars and Courts
US District Court for the Southern District of New York, 1990
New York State Bar, 1990
US Tax Court, 1983
District of Columbia Bar, 1980

Education
MLT, Georgetown University Law Center, 1984
JD, Catholic University of America, 1980
BA, University of Texas at Austin, 1970

Professional Associations and Memberships
District of Columbia Bar Association, Chair, Tax Section
New York Bar Association, Taxation and Financial Instruments Committee
American Bar Association, Taxation and Financial Transactions Committee
Federal Bar Association
The American Law Institute
International Fiscal Association
Tax Coalition
Advisory Board Member, Journal of Taxation of Investments
Advisory Board Member, Journal of Financial Products

Awards and Recognition
International Tax Review, World Tax 2009: Leading Individual
PLC Which lawyer’s 2009 Cross-border Tax on Corporate Transactions Handbook: Prominent Practitioner
The Best Lawyers in America: Tax Law (2007, 2008)
Who's Who in American Law

Recent Publications and Speaking Engagements
Chaired the panel on "Recent International Developments in the Taxation of Financial Products," for a Practising Law Institute Program, April 14, 2009
Panelist on Public-Private Partnerships for Strafford CLE teleconference, April 8, 2009
"Is a Governmental License to Toll a Public Highway a USRPI?" Tax Notes Special Report, March 30, 2009
Chaired the panel on "Financial Products Issues Arising from the Credit Crisis," at the Federal Bar Association, March 6, 2009
Panelist on "Tax Planning Strategies for Derivative Financial Products: Leveraging Tax Benefits from Emerging IRS Guidelines," for a Strafford Publications CLE teleconference, February 2009
Co-author, "NYSBA Members Suggest Further Guidance on Debt Instruments," Tax Notes, January 20, 2009
Testified on "Tax and Financing Aspects of Highway Public-Private Partnerships"at a Hearing of the Subcommittee on Energy, Natural Resources and Infrastructure on Finance, July 24, 2008
"Government Officials Discuss Possible Narrowing of Section 470 Partnership Rules," Derivatives Financial Products Report," June 2006
"IRS: Nonrecognition Treatment for Corporation's Settlement of Contract on its Stock," Tax Notes, January 31, 2005"Character of Income, Deduction, Gain, or Loss from National Principal Contracts, Bullet Swaps, and Forwards is Addressed in Proposed Regulations," Journal of Taxation of Investments, Summer 2004
"Hedging Regs Short on Helpful Guidance, Attack Deferred Comp Hedges," Tax Notes, June 17, 2002
"Proposed Regulations on Hedging Transactions Failed to Address Major Issues," Journal of Taxation of Financial Institutions, September/October 2001
"Hybrid Instruments: A Tax Planning Synopsis," Handbook of Hybrid Instruments, edited by Izzy Nelken, published by John Wiley & Sons, Ltd., 2000

Languages
English

Citizenship
United States